Clause 5: Leadership

Requirement
Top management must demonstrate leadership and commitment in the ways familiar from 2015 (policy and objectives aligned with strategy, integration into business processes, resource availability, communication, achieving intended results, directing and supporting people, promoting continual improvement, supporting other managers).

New in 2026, four items were added: (i) promoting quality culture and ethical behaviour, (j) promoting the use of the process approach, (k) promoting risk-based thinking and opportunity-based thinking, and (l) taking accountability for the effectiveness of the QMS. A new note clarifies that an organisation’s quality culture and ethical behaviour are reflected in its shared values, attitudes, practices, and actions.

How to Implement
This is the item every certification body is flagging as the “biggest practical change” in the revision, since quality culture is now explicitly auditable rather than implied. In practice, top management needs to visibly model and reinforce behaviours such as honesty in reporting nonconformities, fair treatment of staff and suppliers, and transparency with customers, then be able to point to concrete mechanisms, such as a code of conduct, leadership messaging in town halls, or recognition programmes for ethical decision-making, that reinforce these values day to day.

For accountability, top management should personally review QMS effectiveness data (not delegate this entirely) and be prepared to explain, in an audit interview, specific examples of how they have promoted the process approach and risk/opportunity-based thinking in a recent decision.

Mandatory Documents
There is no explicit “shall be available as documented information” statement tied specifically to the quality culture and ethical behaviour promotion activity itself. No single mandatory document is required for this new item. That said, most organisations will want to produce (as useful, non-mandatory, supporting evidence):

• A code of conduct or ethics statement
• Leadership communication records (town hall notes, internal messaging) showing quality culture being actively promoted
• Evidence of management review discussion of quality culture (since this will likely feed into 9.3 going forward)

Requirement
Top management must ensure customer and statutory/regulatory requirements are determined and consistently met, that risks and opportunities affecting product/service conformity and customer satisfaction are addressed, and that focus on enhancing customer satisfaction is maintained. This sub-clause is substantively unchanged from 2015.

How to Implement
Build customer requirements capture into your sales and contract review process, track customer satisfaction trends over time, and ensure that risks to customer satisfaction (late deliveries, quality escapes) are visibly fed into your risk register from Clause 6.

Mandatory Documents
There is no explicit documentation requirement tied to 5.1.2 itself. No mandatory document is required, though customer satisfaction data (covered later under 9.1.2) naturally provides evidence here too.

Requirement
Top management must establish a quality policy that is appropriate to the organisation’s purpose, provides a framework for objectives, commits to meeting applicable requirements and continual improvement, and (unchanged from 2015) takes into account the context of the organisation and supports its strategic direction. The policy must be documented, communicated, available to interested parties as appropriate, and implemented, understood, and applied within the organisation.

How to Implement
Draft a short, high-level policy and have top management formally approve it. Since the policy must now explicitly reflect strategic direction (a theme reinforced throughout the 2026 revision), check that it references, even briefly, how quality supports the organisation’s broader strategic goals rather than reading as a generic, interchangeable statement.

Mandatory Documents
Yes, explicitly mandatory. ISO 9001:2026 states the quality policy “shall be available as documented information.” You must produce and maintain:

• A signed, approved Quality Policy

Requirement
Top management must assign and communicate responsibility and authority for ensuring QMS conformity, reporting on performance, ensuring processes deliver intended results, promoting customer focus, and reporting improvement opportunities. 

New in 2026: a new item (f) requires ensuring the integrity of the QMS is maintained, including when changes to the QMS are planned and implemented.

How to Implement
Appoint a QMS Manager or Management Representative with clear authority, and build a RACI matrix covering the roles above. For the new integrity requirement, explicitly name who is responsible for checking that a proposed change to the QMS won’t undermine existing controls before that change is approved, since this links directly to the expanded 6.3 change management requirements.

Mandatory Documents
There is no explicit “shall be available” statement for 5.3. No mandatory document is required, though a Roles and Responsibilities Matrix is strongly recommended, particularly given the new integrity-during-change accountability.